Justia ERISA Opinion Summaries

Appellee, an employee and participant in Hilton's retirement plan, sued for violations under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001 et seq. Appellee alleged that the Plan's benefit accrual formula was impermissibly backloaded and that Hilton, the Plan sponsor and administrator, violated both ERISA and the Plan by failing to credit certain years of service when calculating employees' vested credit. The court affirmed the district court's finding, that the Plan was impermissibly backloaded and that Hilton failed to calculate participants' vesting credit properly, because the district court handled the case well within its discretion. View "Kifafi v. Hilton Hotel Retirement Plan, et al" on Justia Law

In 1992 Navistar attempted to reduce its costs for retired employee health and life insurance benefits. Navistar’s retirement benefit plan is a registered employee health benefit plan under the Employee Retirement Income Security Act, 29 U.S.C. § 1001 and Navistar is both plan administrator and fiduciary. In 1993, the district court entered judgment in a class action challenging the change, adopting an agreement between the parties and retaining jurisdiction. The Agreement established the Retiree Health Benefit and Life Insurance Plan. The Plan established the Health Benefit Program Summary Plan Description, which contains a description of the health benefits and is furnished to all beneficiaries. The Agreement divides health benefits into two plans: Plan 2 for those eligible for Medicare and Plan 1 for those who are not eligible. A prescription drug benefit was provided under the Agreement, identical for both Plan 1 and Plan 2. When Navistar moved to substitute Medicare Part D into the Plan, class members claimed violation of the Agreement. The district court ordered Navistar to reinstate, retroactively, the prescription drug benefit that was in effect before Navistar made the unilateral substitution. The Sixth Circuit affirmed,View "Shy v. Navistar Int'l Corp." on Justia Law

The district court certified a class consisting of more than 4000 participants in the Meriter pension plan who allegedly were not credited with all benefits to which the plan entitled them. Some members received benefits 23 years ago. Some are current, the rest former, participants. The plan has been amended several times, so claims were divided into 10 groups, each of which was certified as a separate subclass having a different representative under Fed. R. Civ. P. 23(b)(2), which authorizes class action treatment if the defendant “has acted or refused to act on grounds that apply generally to the class, so that final injunctive relief or corresponding declaratory relief is appropriate respecting the class as a whole.” Each subclass in the ERISA action seeks a declaration of the rights of its members under the plan and an injunction directing that the plan’s records be reformed to reflect those rights. Admonishing the attorneys for failing to adequately describe the plan, the Seventh Circuit affirmed. The court rejected arguments concerning conflicts of interest among class members and that class members who are no longer participants in the plan are not entitled to declaratory or injunctive relief because such relief is forward looking. View "Boyd v. Meriter Health Servs. Emp. Ret. Plan" on Justia Law

This dispute related to Employee Retirement Security Act (ERISA), 29 U.S.C. 1001 et seq., contributions made pursuant to a collective bargaining agreement. The district court ordered return of certain allegedly mistaken employer contributions even though the plan administrator determined that the contributions were not made by mistake. Because the court found that the administrator's decision was not an abuse of discretion, the court reversed and remanded for further proceedings. View "U.S. Foodservice, Inc. v. Truck Drivers & Helpers Union" on Justia Law

The Funds brought this action to recover delinquent payments from Park-Mark under the Employee Retirement Income Security Act (ERISA), 29 U.S.C. 1001-1461. Park-Mark contended that it should not be liable for these delinquent payments because it mistakenly made significant overpayments that required a set-off and a refund. The court affirmed the district court's grant of summary judgment in favor of the Funds where the district court did not abuse its discretion by holding that its initial order granting summary judgment disposed of Park-Mark's claim for restitution and the district court properly granted summary judgment in favor of the Funds where equity did not favor a refund on the facts. View "Greater St. Louis Construction, et al v. Park-Mark, Inc." on Justia Law

Raybourne was a quality engineer for 23 years. The employer provided a long-term disability plan that paid benefits for up to 24 months if disability prevented him from performing the duties of his regular job. After 24 months, the plan paid benefits only if he was unable to perform all material duties of any occupation for which he was reasonably qualified. Raybourne suffered degenerative joint disease in his foot, with severe pain. In 2003, he stopped working and underwent the first of the four surgeries. From December 2003 through February 2006, Cigna paid benefits, then determined that he was not disabled under the more stringent standard. Raybourne exhausted administrative remedies, then sued under 29 U.S.C. 1132(a)(1)(B). The district court ruled in favor of Cigna. On remand the court rejected Cigna’s “unconvincing” explanation for how the company determined that Raybourne was not disabled. The court found that Cigna relied on the report of a non-treating physician and on the Social Security Administration’s initial rejections of Raybourne’s claim, failing to consider the SSA’s final determination of disability. The Seventh Circuit affirmed, finding that denial of benefits was based on a conflict of interest rather than on the facts and the terms of the policy. View "Raybourne v. CIGNA Life Ins. Co. of NY" on Justia Law

Barrett, a financial planner, induced the plaintiffs, small New Jersey corporations and their owners, to adopt an employee welfare benefit plan known as the Employers Participating Insurance Cooperative (EPIC). EPIC was promoted as a multiple employer welfare benefit plan for which contributions were deductible under 26 U.S.C. 419A(f)(6), but in fact was a method of deferring compensation. After the Internal Revenue Service audited the plans and disallowed deductions claimed on federal income tax returns, plaintiffs sued Barrett and other entities involved in the scheme, asserting claims under the Employee Retirement Income Security Act of 1974, 29 U.S.C. 1001-1461; the civil component of the Racketeer Influenced and Corrupt Organization Act, 18 U.S.C. 1961-1968; and New Jersey statutory and common law. A jury found Barrett liable of common law breach of fiduciary duty, but not liable on the RICO claim. The district court held a bench trial on the ERISA claim and issued partial judgment for plaintiffs. The Third Circuit affirmed in part, but vacated holdings that deemed certain state law causes of action preempted by ERISA, found certain ERISA claims time-barred, and limited the jury‘s consideration of one RICO theory of recovery. View "Cappello v. Iola" on Justia Law

After they were fired from their jobs, Appellants filed suit in federal district court against their former employer (Employer) and against the severance plan (Plan) established by Employer pursuant to ERISA. The complaint asserted federal claims under ERISA, ADEA, ADA, and other federal laws, and also asserted a breach of contract claim, an employment discrimination claim, and an unjustified dismissal claim under Puerto Rico law. The district court granted Appellees' motion for summary judgment. Appellants challenged that ruling as well as a number of the district court's other orders. The First Circuit Court of Appeals affirmed, holding that there was no error in the management of this case or the grant of Appellees' motion for summary judgment. View "Cruz v. Bristol-Myers Squibb Co., PR, Inc." on Justia Law

While employed at PPG, plaintiffs were represented by three labor unions. In 2001 PPG modified health benefits for retirees, requiring that retirees pay a portion of the cost. The unions thought the modification was a breach of collective bargaining agreements and sued, requesting that the Pennsylvania district court order PPG to arbitrate the benefit dispute with the unions. The district court entered judgment for PPG, holding that the benefits had not vested. The Third Circuit affirmed. Meanwhile, in 2005, more than a year before the district court entered judgment, several individual retirees filed a putative class action in the Southern District of Ohio. Their core allegation was identical to that in the Pennsylvania action; they asserted claims under the Labor Management Relations Act and ERISA and sought monetary damages and an injunction ordering reinstatement of full coverage. The district court held that the Pennsylvania judgment collaterally estopped the plaintiffs from arguing the contrary in this case. The Sixth Circuit reversed. The district court in the Pennsylvania action neither certified a class nor employed any other “special procedures” to protect the retirees’ interests in that action, so the plaintiffs are not bound to that decision. View "Amos v. PPG Indus., Inc." on Justia Law

Plaintiff is the surviving spouse of a 39-year AK employee, who died in 2008, then receiving a monthly pension benefit of $1,386. Plaintiff applied for the surviving spouse benefit and was advised that she was entitled to$693 (50%), reduced by 50% of her social security widow’s benefit (not yet determined), but not less than $140 per month. SSA first advised AK that plaintiff’s monthly benefit would be $458. Weeks later, SSA indicated that the widow’s benefit would be $1469. AK calculated the $140 benefit. Plaintiff received a statement from SSA indicating her widow’s benefit amount was $485 and plaintiff’s own earnings benefit was $973: a total monthly payment of $1,458. Plaintiff calculated that 50% of the $485 widow’s benefit, subtracted from $693, yielded a monthly benefit of $450.50 under the AK Plan. According to AK, $458 represented only the remainder of the entire widow’s benefit, $1,469, after offset for plaintiff’s own old-age retirement benefit, $1,011. In an action under ERISA, 29 U.S.C. 1001, the district court awarded judgment to plaintiff. The Sixth Circuit reversed, holding that AK’s proposed interpretation of the plan language to be truer to its plain meaning when read with reference to the law it expressly refers to. View "Lipker v. AK Steel Corp." on Justia Law